Last Updated: January 2024
Hi, and welcome to this Policy, which describes how we handle your privacy. When you use this website therightcounsellor.com.au (either as a Service Provider or Customer) and the Services provided through it, we collect personal information from you, which we generally use to make the Services available. We care about your privacy and we comply with the principles of the Privacy Act of 1988 (Cth). This is why we have carefully described all the activities we carry out regarding your information under this Policy.
It is also very important that you review other applicable agreements and policies in relation to the Services, especially our Terms of Use. They, together, constitute the entire agreement between you and us in connection with the Services.
By using the Services and by accepting this Policy when you sign up, you consent to how we handle your data. If you do not consent to this Policy, you may not use the Services.
Definition of major terms
“personal information” is any information we hold about you, which is identifiable as being about you. In simple terms, it is any information that can identify who you are (for example, your email address, name, business information, picture, phone number, etc.).
“non-personal information” may include information that cannot identify you. It may also extend to circumstances where we collect anonymous or hashed information such as analytics and usage information collected about visitors.
“Service Provider” is anyone using the Services to provide health related services or any other supported services to Customers.
“Customer” is anyone using the Services to book an appointment with Service Providers.
“user” is a collective name for anyone using the Services – either a Service Provider or Customer.
“Policy” refers to the whole of this privacy policy document.
“Services” refer to business listing, booking services and other applicable uses we provide to you through the website.
“SHMS” refers to SHMS Platform Holdings Pty Ltd (ACN: 643 063 656) as the provider of the website and Services.
The collection of information
We collect personal information and non-personal information in different forms, including the information you provide to us; the information we collect automatically via third-party software; and the information we collect from third parties.
The information you provide to us
We will collect the information you provide to us through the website, when you contact us and when you take other actions. The information you provide mostly contains personal information, such as your name, email address, picture, business address and other information, payment method, etc. You may provide us with this information when you:
- Submit your registration information and update your profile;
- Contact us via our email address or any other channels for support;
- Provide your payment method to pay for subscription fees, receive your earnings or pay for bookings;
- Submit or upload your business information as a Service Provider;
- Submit content on the website, such as feedback or review; and
- Register for any promotion, sweepstakes, surveys, etc.
The information we collect automatically
We may also collect certain personal and non-personal information automatically whenever you access and use this website. We may collect (i) the details of your browser device, including IP Address and other device identifiers; (ii) anonymous information about your behaviours on the website, including the features you click, how long you stay on a particular page, your searches, etc.; and (iii) analytic information about where you came to the website from and so on.
We collect this information automatically through cookies (see the cookie section below) and third-party tracking tools, such as Google Analytics and Firebase (both from Google Inc.). To learn more about Firebase and Google Analytics, and the information they collect, click here. To opt out of Google Analytics from tracking your behaviours on the website, please install the Google Analytics Opt-out Add-on on your browser.
Information we collect from third parties
We may also obtain certain information about you from third parties. For example, where you integrate any of your social media accounts to the Services via the log-in/sign-in page, we will obtain the applicable information from the integrated social media account. We may also obtain information from our marketing partners in order to supplement it with the ones we have to manage and launch our marketing campaigns.
How we use the information collected
We will only use the collected information for the purposes specified under this Policy or any other purposes disclosed at the time of collection. General uses of your information include:
- To provide you access to this website, its features and generally the Services;
- To communicate with you where necessary, including to provide you with updates, news, and market you, as well as provide customer support based on your request;
- To process your payments, including Service Provider subscriptions, earnings and Customer bookings;
- To secure the website, detect fraud, monitor violations of the Services and enforce our Terms of Service;
- To facilitate the interaction and transactions between you and another user of the Services (for example, where a Customer books a Service Provider);
- To host Service Provider business content and other user-generated content (including user reviews and feedback);
- To gather analytics about how the website is used in order to strengthen our marketing and develop new products for business continuity;
- To fulfil our legal obligations as required by applicable laws (for example, where the law requires us to keep records of transactions);
- To display content that matches your behaviors on this website and other platforms; and
- To fulfil any other purposes described to you during collection.
The disclosure of information
therightcounsellor.com.au cares about your privacy – we do not disclose personal information for any other purposes other than as described in this Policy (or any other purposes disclosed at the time of collection). We do not share any personal information with affiliates or third-party service providers for them to market their products to you. However, information about you may be disclosed under the following circumstances:
- Disclosure to employees and applicable individuals within the SHMS company: SHMS employs individuals who help us provide certain services, such as customer support. These employees may have access to your information. However, we will only share information with employees on a need-to-know basis. Likewise, your information may be shared within the SHMS group of companies, including with shareholders or any applicable individual within SHMS.
- Disclosure to third-party service providers: Like employees, we hire contractors and third-party companies (third-party service providers) who help us with services, such as payment processing, fraud detection, website management, database management, etc. Some of these third parties may have access to some personal data about you in order to perform their services. For example, we use third parties like Stripe Inc. and PayPal Inc. to process Customer bookings and Service Provider subscription fees, and for these third parties to process payments, they may require access to your payment information.
- Disclosure to our marketing partners: We may work with third parties, who will help us market our products and services across their platforms. We may share anonymous information about your behaviors on this website with them, and they may use this information to target you with our products and services on their platforms and other platforms. Where you see our ads on other platforms, you may opt out via the opt-out procedure provided on the applicable channel.
- Disclosure to other users of the Services: Where you submit certain user-generated content (for example, where a Service Provider lists its business information or where a Customer submits review), your content will be publicly available, including any attached personal information. Also, where a Customer books a Service Provider, they both will have access to their information, including any personal information shared during the course of their interaction.
- Disclosure under the law: Where we are required by applicable law enforcement to disclose personal information, we will comply with the law (for example, where the government requires that we disclose Service Provider earnings). We may also disclose personal information in circumstances where the disclosure will help protect our intellectual property rights or those of our users or third parties.
- Disclosure under a business change: If SHMS engages in any business transfer or transition activity with another company (for example, a merger, acquisition, sale of assets, consolidation, bankruptcy, etc.), your information may be disclosed to the applicable company.
- Disclosure at your request: There may be certain situations where you instruct us to disclose personal information to a third party. Where you make such a request, we may oblige in accordance with applicable laws and the rights you have under them.
Our use of Cookies
“Cookies” are tiny files, which a website uses to identify you when you come back to the website and to store other details about your use of the website. cookies are NOT malicious programs that access or damage your computer. In relation to this website and the Services, cookies are used by SHMS (first-party cookies) and certain third-party service providers (third-party cookies) to provide certain features, including remembering you, processing payments, displaying contents, securing the website, facilitating your inputs on the website and gathering analytics for marketing on other websites.
Some of the cookies are “session” in nature, which means that they are present on your browser for the duration of a browsing session only – they expire when you close your browser. Other cookies are “persistent,” which means that they have set expiry dates (for example, some cookies are set to expire after 15 minutes).
You can choose to accept or reject cookies when it pops up on your screen or you can disable them from your browser settings area. However, rejecting or blocking cookies may prevent you from taking full advantage of this website. You shall bear any limitations you encounter when you reject cookies.
The security of information
SHMS is committed to ensuring that the information we collect about you is secure and safe. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Regarding your payment method information: we only store information necessary to process your payments or payouts (for example, we will store BSB and account numbers (or PayID) in order to process Service Provider payouts as well as PayPal email addresses). For credit card payments, we do not store your credit card information – we only store the token our payment processor requires to process Customer payments.
For other information, such as your login credentials and profile data, we store it with Firebase via the Firebase react library. This information is transmitted using SSL encryption and other security mechanisms. Furthermore, we will only share personal information within SHMS on a need-to-know basis, and other sharing will be in line with this Policy.
SHMS covenants to use commercially acceptable means of information security in relation to your information; however, we cannot guarantee that your information will at all times be secure due to the nature of the internet.
We do not guarantee that personal information will not be disclosed in manners not consistent with this Policy.
The retention period of your information
We will retain personal information with us for as long as you use the Services or the purpose for which we collect such information is achieved. Where you exercise your right to delete your personal information or account, we will delete your information to the extent possible (see your rights). For any information collected automatically (such as your device IP address), the retention period will depend on the policy practised by Google Inc. as described in the Firebase retention period.
The cross-border transfer of information
SHMS works with third parties from outside of Australia, and we may transfer information about you with them in their respective locations. However, when we transfer personal information to third parties outside of Australia, we ensure adequate protection is applied as described under this Policy.
How you may access and delete your information
Under the Privacy Act of 1988 (Cth), you have the right to request access to and correct the personal information we hold about you. You may request access to and correct your information by emailing us at support@therightcounsellor.com.au
Likewise, you have the right to request that we delete the information we hold about you (this usually means closing down your user account). You may send your request to us at support@therightcounsellor.com.au. Please, note that the deletion of your information is to the extent possible. If the deletion will override our legitimate interest; if it will go against any applicable law; if the information is subject to any ongoing investigation between you and another user; or if the information exists on certain public areas of this website (for example, your reviews), it may be impossible to delete it.
If you believe that we are not using personal information about you as described under this Policy, you may reach out to us to make a complaint at support@therightcounsellor.com.au. If you are not satisfied with our response, you may reach out to the Office of the Australian Information Commissioner (OAIC).
Third-party services
The third-party service providers we use to provide some of the Services have separate policies that govern their privacy practices regarding the information we share with them. You may learn more by reviewing their policies. Where you request the deletion of your information, please be aware that such information may still exist with third-party service providers. We do not have any control over their privacy practices.
Also, this website may contain links, adverts, products and services that lead to certain third-party websites. When you link to a third-party website through this website and use their services, you do so at your sole risk. This Policy does not govern the privacy practices of any third party, including third-party service providers, Service Providers and any other third party. When you submit personal information to any third party, their privacy policy will govern. We advise that you review the policies of these third parties before submitting information to them.
Children policy
The Services and this website are provided only to people of at least 18 years of age. We do not knowingly solicit personal information from individuals below 18 years of age. By signing up to use the Services and submitting personal information to us, you represent that you are at least 18 years of age.
Changes to this Policy
Please be aware that we may review and change this Policy in the future. We may modify this Policy at any time, at our sole discretion, and all modifications will be effective immediately upon our posting of the modifications on this website, dashboard or your email address. Please check back from time to time to review this Policy.
Information about us
This website and the Services provided to you through it are provided by SHMS Platform Holdings Pty Ltd (ACN: 643 063 656). If you have any questions, enquiries, issues, feedback, suggestions, ideas or opinions regarding this Policy or the Services, please reach out to us via support@therightcounsellor.com.au.